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Volume 23.04

Many providers are dealing with significant delays in processing Medicare enrollment updates and new enrollment applications.  It is not unusual to see approvals of CMS 855 filings taking four months to a year.  Change of ownership and new enrollment applications, based on our recent experience, are taking the longest time to get approved.  While we understand why certain filings may take longer than others, the timeliness of enrollment application approvals appears to be slow.  Securing a timely review and approval is important for many reasons.  Delays can cause the provider a significant amount of time and expense.

The following timelines are reported on the websites of the respective Medicare Administrative Contractors (“MACs”).  Of course, timelines can be extended when additional information is required from the provider or other extenuating circumstances arise.  When additional information is required, the provider is generally allowed thirty (30) days to provide the requested information.

Palmetto GBA (average processing days to complete)
Paper application – accurate at submission                           14 days
Paper application – incomplete at submission                      35 days
Internet PECOS submission – accurate at submission           7 days
Internet PECOS submission – incomplete at submission    35 days

NGS (goal)
Paper application                            30 days
Internet PECOS submission           15 days

Typical completion                         45-60 calendar days

Unfortunately, providers cannot rely on the timelines provided by the MACs on their websites.  Most enrollment applications, regardless of how minor the enrollment change may be, are not being approved on a timely basis compared to their own published timeframes.  The current focus by CMS on program integrity, including upcoming CMS Form 855 changes and additional information to be provided, will cause enrollment application approvals to extend even beyond those currently being experienced.  Providers need to focus on reporting changes at the earliest opportunity, ensuring the enrollment application is complete and accurate, and continually monitor the status of enrollment applications submitted.

First Coast Service Options, Inc. (MAC for enrollment applications in certain locations) has reported that CMS has established timeliness standards for processing enrollment applications as follows:

PECOS web applications (initial enrollment or change of information with no site visit) – 95% must be processed within 15 days, paper-based applications (initial enrollment or change of information with no site visit) – 95% must be processed within 30 days, and paper-based applications (initial enrollment or change of information with site visit) – 95% must be processed within 65 days.


We get many questions regarding changing cost reporting periods.  Changing cost reporting periods may be especially important when acquiring another provider.  The following are noteworthy:

  • A change in the cost reporting period must be submitted to your respective MAC at the address where cost reports are submitted unless the MAC has provided a specific individual to contact.
  • The request must be made at least 120 days before the close of the requested cost reporting year-end.
  • The reason for the requested change must be provided.
  • A cost reporting period change cannot be made via a CMS 855 filing.